SecProbe.io

CORRESP
1
filename1.htm

    Morrison Warren

Partner

    Chapman and Cutler LLP

    320 South Canal Street, 27th Floor

    Chicago, Illinois 60606

    T 312.845.3484

    warren@chapman.com

December 1, 2023

VIA EDGAR CORRESPONDENCE

Samantha Brutlag, Esq.

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Re: Exchange Traded Concepts Trust

File Nos. 333-156529 and 811-22263

Dear Ms. Brutlag:

This letter responds to your
comments regarding the registration statement filed on Form N-1A for Exchange Traded Concepts Trust (the “Trust”)
with the staff of the Securities and Exchange Commission (the “Staff”) on September 22, 2023 (the “Registration
Statement”). The Registration Statement relates to Range Nuclear Renaissance ETF, Range Global Coal ETF, Range Global LNG Ecosystem
ETF, and Range Global Offshore Oil Services ETF (the “Funds”), each a series of the Trust. Capitalized terms used herein,
but not otherwise defined, have the meanings ascribed to them in the Registration Statement.

Comment
1

Please provide the Staff each
Fund’s ticker symbol and completed fee table and expense example at least one week before the registration statement is effective.

Response
to Comment 1

Pursuant to the Staff’s
comment, a completed fee table and expense example for each Fund is forth on Exhibits A-D. Additionally, the ticker symbols for
each Fund are set forth below.

    Range Nuclear Renaissance Index ETF

    NUKZ

    Range Global Coal Index ETF
    COAL

    Range Global LNG Ecosystem Index ETF
    LNGZ

    Range Global Offshore Oil Services Index ETF
    OFOS

Comment
2

Please change the name of
each Fund or explain to the Staff how the companies that make up the applicable Fund’s 80% test are primarily engaged in the industry
represented by that Fund’s name (i.e., as applicable, the nuclear industry, coal industry, liquified natural gas industry,
or offshore oil industry). Please provide the Staff the current list of companies in the index and their allocation. Please provide the
Staff with a copy of the index methodology.

Response
to Comment 2

Pursuant to the Staff’s
comment, each Fund’s name has been revised, as set forth below, to include the word “Index” in its name. This inclusion
serves to clarify that a Fund will invest at least 80% of their assets in the components of the applicable index in compliance with Rule
35d-1 of the 1940 Act, as set forth below.

    Range Nuclear Renaissance Index ETF

    Range Global Coal Index ETF

    Range Global LNG Ecosystem Index ETF

    Range Global Offshore Oil Services Index ETF

The Registrant relies upon
the guidance provided by the Securities and Exchange Commission in the Adopting Release to the recently amended Rule 35d-1 of the 1940
Act, as it relates to funds that seek to include the name of the index they track in the name of the fund, the relevant portion of which
is set forth below:

We acknowledge that many investors that
invest in index funds are seeking exposure to a particular index and that funds will have names that reflect the index that they track.
However, terms used in fund names, including index funds, can communicate an investment focus that creates a reasonable expectation among
investors that the fund will hold investments that support that focus. While we recognize the practical constraints and potential for
investor confusion raised by commenters, we believe permitting index funds not to consider the relationship between the terms in their
name and the investment focus such terms convey undermines the investment protection concerns that underlie the names rule and section
35(d). If a fund’s name indicates an investment focus, such as investments in a specified industry, investors reasonably will expect
that there is a meaningful nexus between fund's investments and the fund's investment focus—regardless of whether the fund executes
its strategy by selecting companies in the specified industry or tracking an index that identifies such companies. As a result, consistent
with rule 38a–1, index funds should generally adopt and implement written policies and procedures reasonably designed to ensure
that indexes selected by a fund do not have materially misleading or deceptive names themselves.

In connection with this guidance,
the Registrant, in compliance with its policies and procedures, has considered the name of each index in the context of each index’s
methodology, and determined that the inclusion of the name of the index in each Fund’s name does not make the Fund’s name
materially misleading or deceptive under Section 35(d) of the 1940 Act.

Additionally, a current list
of the companies in each index, their allocation and a copy of each index methodology has been provided under separate cover.

Comment
3

With respect to each Fund,
what percentage of the applicable index consists of companies in the Pure Play category?

Response
to Comment 3

Pursuant to the index methodologies
that have been provided under separate cover, each index does not seek to allocate a specific percentage of its index weight to companies
in the “Pure Play” category. The percentage of index weight allocated to “Pure Play” companies will vary based
upon issuer-specific conditions. Nonetheless, the index provider and Registrant have confirmed that a significant portion of each Fund’s
holdings will be invested in “Pure Play” companies.

Comment
4

The Registrant notes that
alphabetically ordering the principal risks allows shareholders to more easily and quickly locate particular risk disclosure within the
list of risks and provides for easier comparison of risks across funds. The Registrant also notes that Form N-1A does not require a particular
method of listing a fund’s principal risks. Therefore, the Registrant respectfully declines to reorder the principal risks at this
time.

Response
to Comment 4

The Trust notes that alphabetically
ordering the principal risks allows shareholders to more easily and quickly locate particular risk disclosure within the list of risks
and provides for easier comparison of risks across funds. The Trust also notes that Form N-1A does not require a particular method of
listing a fund’s principal risks. Therefore, the Trust respectfully declines to reorder the principal risks at this time.

Comment
5

With respect to the Range
Global LNG Ecosystem ETF, please add disclosure explaining the term “ecosystem” as used in the Fund’s name.

Response
to Comment 5

Pursuant to the Staff’s
comment, the following disclosure has been added to the first paragraph of the section of the prospectus entitled “Principal Investment
Strategies”:

The Index is designed to track the performance
of companies that are involved in the liquefied natural gas ecosystem (the “LNG Ecosystem”), which refers to the complex
system relating to the various stages of production, exploration, development, transportation, and distribution of liquified natural gas
(“LNG Companies”). (emphasis added)

Comment
6

Similarly, with respect to
the Range Global Offshore Oil Services ETF, please add disclosure explaining the term “ecosystem” as used in the Fund’s
principal investment strategy section.

Response
to Comment 6

Pursuant to the Staff’s
comment, the following disclosure has been added to the first paragraph of the section of the prospectus entitled “Principal Investment
Strategies”:

The Index is designed to track the performance
of companies that are involved in the offshore oil services ecosystem (“Offshore Oil Ecosystem”), which refers to the
complex system relating to the various stages of production, exploration, development, transportation, and distribution of offshore oil
(“Offshore Oil Companies”). (emphasis added)

Comment
7

With respect to the Item 9
principal investment strategies section, please consider bolding the last sentence relating to defensive positions.

Response
to Comment 7

Pursuant to the Staff’s
comment, the referenced disclosure has been revised accordingly.

* * * * * * * * * * * * * * *
* * * * * *

Please call me at (312) 845-3484
if you have additional comments or wish to discuss any of the foregoing responses. Thank you.

    Very truly yours,

    Chapman and Cutler llp

    By:
    /s/ Morrison C. Warren

    Morrison C. Warren, Esq.

 cc: Richard Malinowski, Esq., Vice President and Secretary of Exchange Listed Funds Trust

Richard Coyle, Esq., Partner,
Chapman and Cutler LLP

Exhibit
A

Range Nuclear
Renaissance Index ETF

Fees and Expenses

This table describes the fees and expenses that
you may pay if you buy, hold, and sell shares of the Fund. You may pay other fees, such as brokerage commissions and other fees to
financial intermediaries, which are not reflected in the table and Example below.

    Annual Fund Operating Expenses

    (expenses that you pay each year as a percentage of the
    value of your investment)

    Management Fee
    0.85%

    Distribution and Service (12b-1) Fees
    0.00%

    Other Expenses1
    0.00%

    Total Annual Fund Operating Expenses
    0.85%

1 Based
on estimated amounts for the current fiscal year.

Example

This Example is intended to help you compare the
cost of investing in the Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Fund for the
time periods indicated and then sell all of your shares at the end of those periods. The Example also assumes that your investment has
a 5% return each year and that the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower,
based on these assumptions your cost would be:

    1 Year
    3 Years

    $87
    $271

Exhibit
B

Range Global
Coal Index ETF

Fees and Expenses

This table describes the fees and expenses that
you may pay if you buy, hold, and sell shares of the Fund. You may pay other fees, such as brokerage commissions and other fees to
financial intermediaries, which are not reflected in the table and Example below.

    Annual Fund Operating Expenses

    (expenses that you pay each year as a percentage of the
    value of your investment)

    Management Fee
    0.85%

    Distribution and Service (12b-1) Fees
    0.00%

    Other Expenses1
    0.00%

    Total Annual Fund Operating Expenses
    0.85%

1 Based
on estimated amounts for the current fiscal year.

Example

This Example is intended to help you compare the
cost of investing in the Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Fund for the
time periods indicated and then sell all of your shares at the end of those periods. The Example also assumes that your investment has
a 5% return each year and that the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower,
based on these assumptions your cost would be:

    1 Year
    3 Years

    $87
    $271

Exhibit
C

Range Global
LNG Ecosystem Index ETF

Fees and Expenses

This table describes the fees and expenses that
you may pay if you buy, hold, and sell shares of the Fund. You may pay other fees, such as brokerage commissions and other fees to
financial intermediaries, which are not reflected in the table and Example below.

    Annual Fund Operating Expenses

    (expenses that you pay each year as a percentage of the
    value of your investment)

    Management Fee
    0.85%

    Distribution and Service (12b-1) Fees
    0.00%

    Other Expenses1
    0.00%

    Total Annual Fund Operating Expenses
    0.85%

1 Based
on estimated amounts for the current fiscal year.

Example

This Example is intended to help you compare the
cost of investing in the Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Fund for the
time periods indicated and then sell all of your shares at the end of those periods. The Example also assumes that your investment has
a 5% return each year and that the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower,
based on these assumptions your cost would be:

    1 Year
    3 Years

    $87
    $271

Exhibit
D

Range Global
Offshore Oil Services Index ETF

Fees and Expenses

This table describes the fees and expenses that
you may pay if you buy, hold, and sell shares of the Fund. You may pay other fees, such as brokerage commissions and other fees to
financial intermediaries, which are not reflected in the table and Example below.

    Annual Fund Operating Expenses

    (expenses that you pay each year as a percentage of the
    value of your investment)

    Management Fee
    0.85%

    Distribution and Service (12b-1) Fees
    0.00%

    Other Expenses1
    0.00%

    Total Annual Fund Operating Expenses
    0.85%

1 Based
on estimated amounts for the current fiscal year.

Example

This Example is intended to help you compare the
cost of investing in the Fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the Fund for the
time periods indicated and then sell all of your shares at the end of those periods. The Example also assumes that your investment has
a 5% return each year and that the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower,
based on these assumptions your cost would be:

    1 Year
    3 Years

    $87
    $271